Doctrine by topic · DGT Observatory

Financial Intermediation: DGT doctrinal evolution

How the DGT's position on this topic has evolved, and the rulings it rests on.

← DGT Observatory

How the DGT's position has evolved

Settled doctrine High confidence 23 rulings · 2014–2025

Current position

Financial intermediation is exempt from IVA (Value Added Tax) if the provider acts as an independent third party that brings the parties together for a future contract. This task must go beyond the mere provision of information or the receipt of requests. Advertising services, data transfer, or web space reservation are not considered ancillary to the mediation and are subject to the tax.

The DGT's position has remained constant over time, requiring that mediation be an activity of bringing parties together that transcends simple information management. Throughout the rulings, the need for an independent third party has been reiterated, and it has been specified that services such as advertising or payment management do not form part of the exemption.

Turning points

  1. V4121-15

    Establishes that payment management through virtual POS, acting as the responsible party in the payment chain, qualifies as financial intermediation.

  2. V2177-19

    Specifies that for online mediation, the exemption requires that the client be able to enter into the contract through the medium used itself.

Analysis based on 23 of 23 rulings with a stated position. Updated 24 September 2026.

Rulings on this topic

23

Apply this to your case

VAT advisoryTalk to the team applying this doctrine daily.
Talk to the tax teamWe check whether this criterion affects you and what it means in your situation.
Email
Contact